The defendants include Raymond “Shrimpboy” Chow, the current Dragonhead, or leader, of the San Francisco-based Chee Kung Tong organization (CKT), and State Senator Leland Yee, who represents San Mateo County and part of San Francisco County in the California Senate.

With respect to Chow, according to the Complaint, as FBI undercover agents infiltrated the CKT through introductions made by Chow and others, a pattern of alleged racketeering activity was uncovered.

According to the Complaint, as the relationship developed among the primary undercover agent, Chow, and other defendants, the undercover agent informed the defendants that he was interested in generating income from illegal schemes. The undercover agent was inducted into the CKT as a “Consultant.” Thereafter, during the course of multiple undercover operations, the undercover agent was allegedly introduced to a number of the defendants in order to launder money, traffic narcotics, traffic in firearms, traffic purportedly stolen cigarettes and liquor, and engage in murder-for-hire schemes.

Chow also introduced Keith Jackson to the undercover agent. Jackson, the owner and operator of “Jackson Consultancy,” a San Francisco based consulting firm, is a “Consultant” to the CKT. Jackson and his son, Brandon Jackson, allegedly responded to a request for weapons by the undercover agent, by indicating that Brandon Jackson, and an associate would be able to accommodate his request. Subsequently, Jackson, Brandon Jackson, and Marlon Sullivan sold various types of firearms, and two ballistic vests, to the undercover agent. Additionally, Jackson, Brandon Jackson, and Sullivan allegedly conspired to commit a purported murder for hire scheme requested by the undercover agent, in addition to other illegal activity, including the sale of stolen credit cards and the purported sale of cocaine to Jackson, Brandon Jackson, and Sullivan from the undercover agent.

Brandon Jackson introduced the undercover agent to Rinn Roeun, one of Brandon Jackson’s sources of supply for firearms. Roeun sold multiple firearms to the undercover agent and, during a series of conversations, told the undercover agent that he was willing to commit murder for a fee.

According to the Complaint, in addition to his relationship with Chow, and the CKT, Keith Jackson is also a close associate of Senator Leland Yee. From at least May 2011 through the present, Jackson has been involved in raising campaign funds for Yee.

With respect to Yee, the Complaint alleges that over the course of 2012 and continuing to the present time, Yee and Keith Jackson allegedly raised money and campaign funds for Yee’s Secretary of State campaign by soliciting donations from FBI undercover agents, in exchange for multiple official acts, and that Yee and Jackson were involved in a conspiracy to traffic firearms.

Starting in May 2011, according to the Complaint, and continuing for several months, Jackson solicited an undercover agent with the FBI to make contributions to Yee’s San Francisco mayoral campaign. These solicitations allegedly included asking the agent for donations in excess of the $500 individual donation limit. The agent declined to make any donations to Yee, but introduced Jackson and Yee to a purported business associate, another undercover FBI agent. Jackson and Yee then solicited the second undercover agent for campaign contributions. This solicitation resulted in at least one personal donation in the amount of $5,000 to Yee’s mayoral campaign.

After Yee lost the November 8, 2011, election, according to the Complaint, he had at least $70,000 in debt from that campaign. In connection with efforts to retire the mayoral campaign debt, according to the complaint, Yee and Jackson allegedly agreed that Yee would make a telephone call to a manager with the California Department of Public Health in support of a contract under consideration with the second undercover agent’s purported client, and would provide an official letter of support for the client, in exchange for a $10,000 campaign donation. Yee allegedly made the call on October 18, 2012, and provided the letter on or about January 13, 2013. On November 19, 2012, Jackson accepted the $10,000 cash donation.

According to the Complaint, in a further attempt by Jackson and Yee to gain money from one of the undercover agents, in August 2013, Jackson told the undercover agent that Yee had a contact who deals in arms trafficking. Jackson requested that the undercover agent provide a campaign donation on behalf of Yee, for Yee to facilitate a meeting with the arms dealer with the intent of the undercover agent to purportedly purchase a large number of weapons. During a meeting with the undercover agent, Yee and Jackson allegedly discussed details of the specific types of weapons the undercover agent was interested in buying and importing.

The defendants are charged as follows:

LELAND LIN YEE

Conspiracy to Traffic in Firearms Without a License, and to Illegally Import Firearms, in violation of 18 U.S.C. § § 371, 922(a)(1), and (l)

Conspiracy to Traffic in Firearms Without a License, and to Illegally Import Firearms, in violation of 18 U.S.C. § § 371, 922(a)(1), and (l)

In a related case, a complaint filed on March 25, 2014, charging defendant BARRY HOUSE with one count of trafficking in firearms without a license, in violation of 18 U.S.C. § 922(a)(1), and one count of felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1).

The maximum penalties for the violations are as follows:

18 U.S.C. § 1956(a)(1)

Twenty years in prison
Three years supervised release
$500,000 fine
$100 special assessment

18 U.S.C. § 1956(a)(3)

Twenty years in prison
Three years supervised release
$500,000 fine
$100 special assessment

18 U.S.C. § § 371,
2314, 2315

Five years in prison
Three years supervised release
$250,000 fine
$100 special assessment

18 U.S.C. § § 371, 2315,
2342(a), 2344

Five years in prison
Three years supervised release
$250,000 fine
$100 special assessment

18 U.S.C. § 922(a)(1)

Five years in prison
Three years supervised release
$250,000 fine
$100 special assessment

18 U.S.C. § 922(g)(1)

Ten years in prison
Three years supervised release
$250,000 fine
$100 special assessment

18 U.S.C. §§ 371,
922(a)(1), 922(l)

Five years in prison
Three years supervised release
$250,000 fine
$100 special assessment

18 U.S.C. § 924(c)

From five years to life
Five years supervised release
$250,000 fine
$100 special assessment

18 U.S.C. § 1958

Ten years in prison
Three years supervised release
$250,000 fine
$100 special assessment

18 U.S.C. § § 1343,
1346, 2

Twenty years in prison
Three years supervised release
$250,000 fine
$100 special assessment

21 U.S.C. § 841

From five years to forty years in prison
Four years supervised release
$5 million fine
$100 special assessment

21 U.S.C. § 841, 846

Five years in prison,
with five or ten year mandatory minimum
in some instances
Three to five years supervised release
$250,000 to $10 million fine
$100 special assessment

The defendants, with the exception of Brandon Jackson, Sullivan, Liang, Nhingsavath, Mastrangelo, Gee, Yun, and Pau, were arrested today and made their initial appearances in federal court in San Francisco in front of United States Magistrate Judge Nathanael M. Cousins.

Yun and Pau were arrested yesterday in New York. Sullivan was arrested this morning in New Jersey and Brandon Jackson was arrested in Connecticut. Liang, Nhingsavath, Mastrangelo, and Gee are fugitives.

A complaint merely alleges that crimes have been committed, and all defendants are presumed innocent until proven guilty beyond a reasonable doubt. If convicted, the defendants are subject to the maximum penalties stated above. However, any sentence following conviction would be imposed by the court only after consideration of the U.S. Sentencing Guidelines and the federal statute governing the imposition of a sentence, 18 U.S.C. § 3553.

William Frentzen, Susan Badger, and Waqar Hasib are the Assistant U.S. Attorneys who are prosecuting the case. The prosecution is the result of a five-year investigation by the FBI, Internal Revenue Service-Criminal Investigations Division, San Francisco Police Department, Oakland Police Department, and Antioch Police Department.